Insights for maritime operations

Both the paper Oil Record Book and an approved electronic one are legal under MARPOL Annex I. The amendments in IMO resolution MEPC.314(74), in force since 1 October 2020, added the electronic record book as a lawful alternative, with the guidelines in MEPC.312(74) setting the conditions. So this is not a choice between a compliant option and a non-compliant one. It is a choice between two media that have to satisfy the same regulation in different ways, and they handle some of those requirements very differently.

For most of MARPOL’s history there was one lawful way to keep an Oil Record Book: ink on the paper form. That changed on 17 May 2019, when the IMO’s Marine Environment Protection Committee adopted resolution MEPC.312(74), the “2019 Guidelines for the use of electronic record books under MARPOL,” at its 74th session. The companion amendments to MARPOL, in resolution MEPC.314(74) adopted the same day, entered into force on 1 October 2020 and added a definition of an electronic record book to Annex I and the parallel annexes. From that date a ship can keep its Oil Record Book electronically, provided the system meets the guidelines and the flag administration approves it.

The Oil Record Book is one of the documents a Port State Control officer reaches for early in an inspection. It is required on board under MARPOL Annex I, it is supposed to be current and signed, and it can be checked against the physical evidence in the engine room. When the entries, the equipment counters, and the tank soundings do not line up, the book is where the discrepancy shows. That is why the ORB has long been a focus of PSC, and why falsified Oil Record Books have been the basis of pollution prosecutions, including cases brought under the United States Act to Prevent Pollution from Ships.

The single point that decides whether an electronic Oil Record Book is lawful is not the software. It is the flag Administration’s approval. The MARPOL amendments in IMO resolution MEPC.314(74), in force since 1 October 2020, allow an electronic record book in place of paper, but only one the ship’s Administration has approved. A type-approved product is the precondition; the flag state’s acceptance is the act that makes it legal on a particular ship. Buyers who treat the purchase as the finish line discover the gap at the first Port State Control inspection.

Since 1 October 2020, when the MARPOL amendments in IMO resolution MEPC.314(74) entered into force, a ship can keep its Oil Record Book electronically instead of on paper. For a single vessel the change is about how the book is kept. For a fleet, it changes something larger: the company gets a live view of compliance across every ship, the kind of view paper has never allowed. This article looks at what actually changes when a fleet makes the move, past the obvious point that there is less paperwork.